Response 968617726

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Direct Payments (Pillar 1)

6. Considering how funding is currently distributed across CAP schemes, do you have initial views about how the balance between these schemes should change in future to maximise outcomes?

Considering how funding is currently distributed across CAP schemes, do you have initial views about how the balance between these schemes should change in future to maximise outcomes?
Strengthen the focus on payments by outcome rather than entitlement.

7. Do you agree that changes to capping are a useful measure to enhance the positive social and environmental impact of agricultural policy?

Do you agree that changes to capping are a useful measure to enhance the positive social and environmental impact of agricultural policy?
Yes.

9. Should there be a maximum cap on the total funding a business receives from all schemes, or a scheme-by-scheme approach?

How can the aims of LFASS be better achieved/would you prefer to see alternative methods of providing support?
Maximum on total from all schemes to ensure greater equity across business types (must include LFASS).

10. How can the aims of LFASS be better achieved/would you prefer to see alternative methods of providing support?

How can the aims of LFASS be better achieved/would you prefer to see alternative methods of providing support?
introduce a clearer set of objectives and required outcomes, current scheme is horizontal support on basis of entitlement and represents a poor use of money for little if any demonstrated benefit, evaluation of LFASS shows little real outcome other than supporting land managers in these areas. It is a blunt and ineffective instrument and contributes to inertia allowing 'place sitters' to remain in holdings at the expense of new entrants or business types. Take the opportunity to redesign this completely for the benefit of all of rural Scotland

11. Would you see value in directing future LFA support through other existing Direct Payment Schemes?

Would you see value in directing future LFA support through other existing Direct Payment Schemes?
Only if it strengthened outcomes benefiting rural areas (not just farming).

12. Do you think there are administrative and operational simplifications that would benefit current or future LFASS claimants?

Do you think there are administrative and operational simplifications that would benefit current or future LFASS claimants?
No, the transaction cost for the payment received is minimal compared to other forms of support

14. Do you support the use of regional pilots to help tailor schemes to local circumstances?

Do you support the use of regional pilots to help tailor schemes to local circumstances?
Yes, essential.

16. Do you have views on how the penalty regime – particularly around fairness, transparency, the maintenance of standards and compliance burden – could be improved in the short-term?

Do you have views on how the penalty regime – particularly around fairness, transparency, the maintenance of standards and compliance burden – could be improved in the short-term?
Increase rigour.

17. Are there specific issues you think the SimplificationTask Force should prioritise for review?

Are there specific issues you think the SimplificationTask Force should prioritise for review?
Reduce gold plating by Scottish Govt (frequently and wrongly blamed on EU rules)

19. If new schemes seek to encourage collaboration, enhance skills development, help with capacity building, facilitate wider integration into the supply chain, promote carbon audits and monitoring of the soil health, how might pilot projects be best designed to help test and develop new approaches?

If new schemes seek to encourage collaboration, enhance skills development, help with capacity building, facilitate wider integration into the supply chain, promote carbon audits and monitoring of the soil health, how might pilot projects be best designed to help test and develop new approaches?
provide support for communities, businesses to enter process, capacity provision to kick start, this could be done through LEADER as was done in the past (LEADER II and LEADER+)

21. Do you agree to expanding the number and role of Monitor Farms or similar during the transition period? Do you have any ideas as to how Monitor Farms could be refined or adapted to better meet future needs?

Do you agree to expanding the number and role of Monitor Farms or similar during the transition period? Do you have any ideas as to how Monitor Farms could be refined or adapted to better meet future needs?
It should be continued and be adaptable in order to emerging needs but should not be expanded as a matter of course.

22. Do you agree with the proposal to look at moving towards a more performance based approach to compliance, using key performance indicators and better information?

Do you agree with the proposal to look at moving towards a more performance based approach to compliance, using key performance indicators and better information?
Absolutely.

23. Do you have views on the types of indicator that should be used or areas of priority action within the operation of current CAP schemes?

Do you have views on the types of indicator that should be used or areas of priority action within the operation of current CAP schemes?
Yes, but would require a book. Should be focused at the result level and be capable of practical real time measurement, not theoretical academic approaches.

Scottish Rural Development Programme (Pillar 2)

32. Would there be customer benefits if the CAGS, small farms capital grant scheme and the new entrants capital grant scheme were combined?

Would there be customer benefits if the CAGS, small farms capital grant scheme and the new entrants capital grant scheme were combined?
Wrong question, benefits for the public purse!

36. Is the LEADER approach something that you could support?

Is the LEADER approach something that you could support?
100% Key means of engaging and empowering rural communities and a means of retaining connections with wider rural development interests and practitioners throughout rural Europe.

37. Considering LEADER in its current form, are there other opportunities to improve the administrative efficiency of the scheme?

Considering LEADER in its current form, are there other opportunities to improve the administrative efficiency of the scheme?
Yes, massive. Too much to write here but would be happy to contribute as a leading EU expert and advisor to DG AGRI on this (Lead responsibility for LEADER in the European Network for Rural Development). Strengthening subsidiarity and trusting local people to use resources in best interests of their area should be the starting point, public money is their money after all!

38. Do you have initial views on the proposal that SRDP broadband support would cease?

Do you have initial views on the proposal that SRDP broadband support would cease?
not an effective tool, rural proof all broadband policy and support provision.

39. Do you have any thoughts on the form, content and delivery methods for future advice?

Do you have any thoughts on the form, content and delivery methods for future advice?
Must be much more beneficiary oriented and better aligned with the achievement of the policy objectives and outcomes sought, insufficiently joined up between policy and delivery in both design and delivery.

40. Do you have any views on the balance of advice delivered by one-to-one and one-to-many methods?

Do you have any views on the balance of advice delivered by one-to-one and one-to-many methods?
There are excellent examples elsewhere in the EU (and UK) which could be considered, e.g. in the food sector the Cywain programme in Wales.

41. Do you have any views on how delivery of advice can be better linked to delivery of results?

Do you have any views on how delivery of advice can be better linked to delivery of results?
There are excellent examples elsewhere in the EU (and UK) which could be considered, e.g. in the food sector the Cywain programme in Wales.

43. Do you have any views on the effectiveness of KTIF and how the aims of the scheme could be promoted in the future?

Do you have any views on the effectiveness of KTIF and how the aims of the scheme could be promoted in the future?
is it promoted? very low visibility to rural business

46. Do you see a continuing role for the Scottish Rural Network (SRN) and, if so, do you agree that its current aims and objectives should be maintained during the transition period?

Do you see a continuing role for the SRN and, if so, do you agree that its current aims and objectives should be maintained during the transition period?
Absolutely, the SRN has been an exemplar for what can be achieved, the step change form the previous iteration is massive, at EU level the current support unit play a prominent role and is effective in strengthening two way interaction. As with LEADER this could be a critical factor in maintaining rural Scotland's engagement with rural Europe. Again although responding personally as a rural Scot as I am the deputy team leader of the European Network for Rural Development I would be happy to contribute more here.

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